NACUBO Submits Comments on Proposed OMB Guidance

On May 31, 2013, NACUBO sent comments to the Office of Management and Budget (OMB) regarding the agency's proposed reforms and changes to federal grants management. OMB's goal is to supersed and streamline requirements from eight existing OMB Circulars into comprehensive guidance for all types of entities.

Dear Mr. Werfel:

I am writing on behalf of the National Association of College and University Business Officers (NACUBO) to submit the following comments on the Notice of Proposed Guidance on the "Reform of Federal Policies Relating to Grants and Cooperative Agreements; Cost Principles and Administrative Requirements (including Single Audit Act)" published in the Federal Register on February 1, 2013.

NACUBO represents chief financial officers and business office staff at more than 2,100 public and independent colleges and universities. In its capacity as a professional association, NACUBO issues accounting and reporting guidance for the higher education industry and educates over 2,000 higher education professionals annually on accounting and reporting issues and practices including government regulatory compliance. NACUBO's mission is to advance the economic viability, business practices, and support for higher education institutions in fulfillment of their missions.

Overall, NACUBO is pleased with the objectives of this project and agrees with a number of areas of the guidance that OMB has proposed. We appreciate OMB abandoning the flat indirect cost rate proposal that was suggested in last year's Advance Notice of Proposed Guidance. Furthermore, NACUBO agrees with OMB's decision to offer entities an extension of their current negotiated indirect cost rates for a period of up to four years, as described in .616(e). In that same spirit, we believe the language in .506(b) that allows for electronic records substitution will be beneficial to our member institutions. Finally, we are thankful to OMB for extending the comment period on the proposed guidance by 30 days.

NACUBO endorses the comments submitted by the Council on Governmental Relations (COGR). Further, we urge OMB to carefully consider comments submitted by the American Institute of Certified Public Accountants (AICPA) relating to proposed changes to A-133, as the AICPA is the only organization with the expertise to assess the impact on auditor time, effort, and ultimately, reliance on audit results. In our letter, we would like to expand upon several issues discussed in the comment letters provided by COGR and the AICPA. Grants reform, while critically important to those involved in managing grants at our member institutions, also affects business officers involved with procurement, payroll, property accounting, information technology, and financial reporting. Rather than duplicate points made with respect to research administration, we wish to highlight concerns specific to the business officer community.